Prison Farms Conflict of Interest

Mario Dion
Conflict of Interest and Ethics Commissioner
Office of the Conflict of Interest and Ethics Commissioner
Parliament of Canada
Centre Block, P.O. Box 16
Ottawa, Ontario K1A 0A6


July 27, 2018

Dear Mr. Dion,

We are writing to report contraventions of the Conflict of Interest Act as it applies to Public Safety Minister Ralph Goodale and public office holders appointed by him to advise on the return of Correctional Service Canada’s prison farm program. In this letter we will explain the circumstances and evidence of the breaches, and we formally request that you investigate this matter, on your own initiative, in defence of justice and Canadian democratic values.

In 2016, the federal government launched a feasibility study and public consultation process into reopening prison farms, which falls under the purview of Minister of Public Safety Ralph Goodale. In 2017, Minister Goodale appointed an advisory panel “to help us determine the best way ahead for re-establishing penitentiary farms.”

The Prison Farm Advisory Panel was composed exclusively of leadership and supporters of the activist group Save Our Prison Farms, despite clear Conflict of Interest Act rules prohibiting Minister Goodale from “providing preferential treatment to any person or organization based on the identity of the person or organization.” (s. 7)

All appointed members of the panel were prison dairy advocates, and the majority were livestock farmers, suggesting that only animal agriculture was under consideration. Our group, Evolve Our Prison Farms, advocating ethical and environmentally sustainable models for the rehabilitation program, immediately issued a letter to Minister Goodale expressing concern over the composition of the panel:

“A citizen advisory panel appointed by the federal government must aspire to a high level of balanced representation and commitment to evidence-based policy recommendations. Given that several members of the panel have already made clear that their single-minded goal is reinstatement of animal agriculture, the panel as it stands fails the test.

We call on you to ensure more balanced representation and less biased consideration of the options.”

No response or review was issued, and the advisory panel proceeded to work in direct collaboration with CORCAN and Minister Goodale. To date, Minister Goodale has refused to meet or speak with our group, despite our many letters, meeting requests, phone calls, petitions and report submissions.

In March 2018, it was announced that prison goat dairy operations would be established at Joyceville Institution in Kingston, involving up to 1,500 goats, with milk being destined for the Feihe International infant formula factory to be processed and shipped to China.

The Save Our Prison Farms activists, while still engaged as members of the Prison Farm Advisory Panel, immediately and publicly lobbied for Minister Goodale to add cow dairy to the prison farms. In June 2018, in direct response to this pressure, it was announced that up to 60 cows would be added. Currently, these public office holders are lobbying to sell the descendants of the former “Pen Herd” cows – which they own – to the government for the prison farm program.

Minister Goodale is clearly bound by the Conflict of Interest Act, as is emphasized in his Mandate Letter from Prime Minister Justin Trudeau (November 2015):

“As Minister, you must ensure that you are aware of and fully compliant with the Conflict of Interest Act… As noted in the Guidelines, you must uphold the highest standards of honesty and impartiality.”

The Mandate Letter also points to the priorities that Minister Goodale is expected to uphold, including:

“constructive dialogue with Canadians, civil society, and stakeholders… the broader public sector… and identifying ways to find solutions and avoid escalating conflicts unnecessarily… 

If we are to tackle the real challenges we face as a country – from a struggling middle class to the threat of climate change – Canadians need to have faith in their government’s honesty and willingness to listen.”

The Conflict of Interest Act also applies to members of the Prison Farm Advisory Panel, as follows:

  • The definition of public office holder includes (c) a ministerial adviser;
  • A ministerial adviser includes a person who provides policy, program or financial advice to a minister, whether or not the advice is provided on a full-time or part-time basis and whether or not the person is entitled to any remuneration or other compensation for the advice;
  • As such, the appointed members of the Prison Farm Advisory Panel constitute public office holders and are bound by the Conflict of Interest Act;
  • Members of the Prison Farm Advisory Panel are therefore not permitted to exercise their power, duty or function to further their private interests.

The following are clear instances of contravention:

  • Minister Ralph Goodale appointed a panel composed of members of a single advocacy group, in breach of [7] Preferential treatment: No public office holder shall, in the exercise of an official power, duty or function, give preferential treatment to any person or organization based on the identity of the person or organization.
  • After the goat dairy decision was announced for Joyceville, members of the Prison Farm Advisory Panel who are leaders of the activist group Save Our Prison Farms and shareholders in the Pen Herd Co-Operative which owns the descendants of the Pen Herd cows, publicly lobbied Minister Goodale to add cow dairy and to purchase their cows for the program, in breach of [9] Influence: No public office holder shall use his or her position as a public office holder to seek to influence a decision of another person so as to further the public office holder’s private interests and [16] Fundraising: No public office holder shall personally solicit funds from any person or organization if it would place the public office holder in a conflict of interest.

The following are instances where further breaches may occur, but which lack public evidence as yet:

  • According to the Kingston Economic Development Commission (KEDCO), there are only two major goat dairy brokers in Ontario. Although the KEDCO employee responsible for the Feihe file could not confirm which broker would be buying the milk from Joyceville Institution, she indicated that there are conveniently a handful of smaller independent goat dairy brokers, one of which is Mariposa Dairy, whose owner is an appointed member of the Prison Farm Advisory Panel. If the sale of milk from Joyceville Institution involves Mariposa Dairy in any way, it would be in breach of multiple Conflict of Interest Act rules.
  • If Minister Goodale agrees to purchase the Pen Herd cows for the prison farm program as a result of the public activism of Save Our Prison Farms leaders while they were bound by and contravening Conflict of Interest Act rules as public office holders, such a decision by Minister Goodale would be in breach of [21] Duty to recuse: A public office holder shall recuse himself or herself from any discussion, decision, debate or vote on any matter in respect of which he or she would be in a conflict of interest.

When Evolve Our Prison Farms met with Kingston MP Mark Gerretsen in February 2017, he informed us that “unless you are Save Our Prison Farms, the government isn’t going to listen to you.” These words have proved true.

All matters weighed, the decisions and actions taken by Minister Goodale, and the structure and actions of the Prison Farm Advisory Panel, contravene Conflict of Interest Act rules, betray the Minister’s mandate, prevent constructive dialogue, escalate conflict, and fail to tackle the challenges that we face as a country.

Prison farms are a federal program that will carry significant rehabilitative, environmental, and social impacts. The future of this Corrections program should not be dictated according to the private interests of a small group of local livestock farmers, yet this is precisely what is occurring.

We appeal to you, Mr. Dion, as Conflict of Interest and Ethics Commissioner, to “enhance the trust and confidence of the Canadian public in the conduct of elected and appointed officials” by investigating this matter on the grounds laid out above.

It would represent a great tragedy for Canada if this is how we conduct matters of democracy and rehabilitation. Private interests must not be permitted to direct the process and outcome of federal correctional programs, or to suppress opportunities and advantages that lie in underexplored possibilities for our prison farms.


Calvin Neufeld & Franceen Neufeld
Co-Founders, Evolve Our Prison Farms


Justin Trudeau, Prime Minister of Canada
Ralph Goodale, Minister of Public Safety and Emergency Preparedness
Anne Kelly, Interim Commissioner of the Correctional Service of Canada
Ivan Zinger, Correctional Investigator of Canada